| FAQ - Miscellaneous - 2014
We have a new dental assistant that is joining our office and has requested to wear a skirt. Are there safety concerns we need to consider or documented recommendations for employees who prefer to wear a skirt?
Ask OSAP can only provide general information that we hope will be beneficial in understanding the regulations governing protective attire.
With regard to regulations, general work clothes are not covered by the Bloodborne Pathogens Standard unless they are intended to function as personal protective equipment (PPE). The employer should first determine if the clothing worn under the outer protective garment (PPE) will be considered "general work clothes" only, or if they are also intended to function as personal protective equipment (PPE).
The US Department of Labor – Occupational Safety and Health Administration (OSHA) states:
[Re: Bloodborne Pathogens Standard]
The standard states the requirements for personal protective clothing in performance language. Paragraph (d)(3)(i) states:
When there is occupational exposure, the employer shall provide, at no cost to the employee, APPROPRIATE personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered "APPROPRIATE" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.
It is the employer's responsibility to evaluate the task and the type of exposure expected and, based on the determination, select the "appropriate" personal protective clothing in accordance with paragraph (d)(3)(i) of the standard. In general, OSHA would expect the employer to select traditional protective clothing, such as clinic jackets, lab coats, or uniforms. 1
As an employer, you must assess your workplace to determine if hazards are present that require the use of personal protective equipment. If such hazards are present, you must select protective equipment and require workers to use it, communicate your protective equipment selection decisions to your workers, and select personal protective equipment that properly fits your workers. 2
In addition to the protections prescribed by the Bloodborne Pathogens Standard, OSHA's Personal Protective Equipment Standard, 29 CFR 1910.132, requires that all employers perform a hazard assessment to determine where hazards exist that necessitate the use of PPE. 3
The US Centers for Disease Control and Prevention's (CDC’s) Guidelines for Infection Control in Dental Healthcare Settings (December 2003) states the following: General work clothes (e.g. uniforms, scrubs, pants, and shirts) are neither intended to protect against a hazard nor considered PPE. 4
Additionally, Practical Infection Control In Dentistry states:
Protective clothing, such as reusable or disposable gowns, laboratory coats, jackets, and uniforms, should be worn when clothing or exposed skin is likely to be soiled with blood or other body fluids. The OSHA bloodborne pathogens standard requires sleeves to be long enough to protect the forearms when the gown is worn as PPE (i.e., when spattering and spraying of blood, saliva, or OPIM to the forearms are anticipated). PPE does not have to be fluid-impervious to meet OSHA standards, but must prevent contamination of skin and underlying clothing. Cotton or cotton/polyester fabrics are acceptable as PPE if the sleeve length is long. DHCP should change protective clothing when it becomes visibly soiled, or as soon as feasible if it has been penetrated by blood or other potentially infectious fluids. 5
The American Dental Association offers this information regarding PPE:
The selection of appropriate PPE requires judgment based on the procedure being performed and the possibility of exposure. In selecting PPE, the goal should be to prevent blood or other potentially infectious materials from reaching the individual’s street clothes or undergarments, skin, eyes, mouth or other mucous membranes. PPE should be changed when it becomes visibly soiled and removed immediately, or as soon as feasible, if it is penetrated by blood or other potentially infectious fluids. All PPE should be removed before leaving the work area. General work clothes (e.g., uniforms, shirts, blouses) that are worn outside the work area are not considered PPE. 6
Gowns and Other Protective Clothing. For most dental procedures, a gown, lab coat or clinic jacket will be sufficient to cover areas of the body exposed to blood or other potentially infectious material. The fabric and style selected will depend on the task and degree of exposure anticipated. Remember that splashes and sprays can travel some distance from the patient’s mouth to land on exposed areas.6
The authors of OSAP’s Interact Training System state that exposed areas of your body have the potential to be contaminated during a dental procedure. PPE is designed to protect your body and consists of clothing, barriers, for the face and eyes, and gloves. When selecting clinical attire, it is important to select clothing that will be a barrier that is appropriate for the procedure being performed. While each dental office must determine what is appropriate attire for their specific procedures or office setting, keep in mind that clinic attire should be protective, sensible, comfortable, and practical. In most cases, however, the extent of coverage of your clinic attire should be complete from the neck to the wrist, and at least to the bottom of the knees. 7
Clinic attire must provide a barrier to any exposed skin and street clothes that have the potential to be contaminated during patient treatment or during other exposure-prone tasks such as operatory setup, take-down, instrument recirculation, laboratory activities, etc. The employer must determine what attire is appropriate for your office. Additional barrier attire may be required for procedures that cause high levels of aerosolization or spatter. 7
It is the employer’s responsibility to conduct a hazard assessment in order to determine if hazards are present that require the use of personal protective equipment (PPE). It is the employer’s responsibility to determine what type of protective clothing is indicated for use to prevent employee street clothing and exposed skin from being soiled with blood or other body fluids. It is the employer’s responsibility to determine if PPE is indicated and what type of PPE is necessary for all employees, including those wearing skirts.
A Google search was conducted regarding dental practice dress codes. You may also possibly find some helpful information at this link:
Please note that there may be varying requirements in those states with State OSHA Programs. Further information about State OSHA Programs can be accessed at:
1) US Department of Labor – Occupational Safety and Health Administration. Standard Interpretation. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=20654 Accessed on January 18, 2014.
2) US Department of Labor – Occupational Safety and Health Administration. OSHA Fact Sheet – Personal Protective Equipment. https://www.osha.gov/OshDoc/data_General_Facts/ppe-factsheet.pdf Accessed on January 18, 2014.
3) US Department of Labor – Occupational Safety and Health Administration. Standard Interpretation. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=28868 Accessed on January 18, 2014.
4) Kohn WG, Collins AS, Cleveland JL, Harte JA, Eklund KJ, Malvitz DM, Centers for Disease Control and Prevention (CDC). Guidelines for infection control in dental health-care settings—2003. MMWR Recomm Rep 2003;52(RR-17):1-61. http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5217a1.htm Accessed on January 18, 2014.
5) Molinari JA and Harte JA. Practical Infection Control In Dentistry – Third Edition. Wolters Kluwer / Lippincott / Williams & Wilkins. Pages 111-112.
6) American Dental Association. Personal Protective Equipment. http://www.ada.org/sections/professionalResources/pdfs/cdc_protective_equipment.pdf
7) OSAP Interact Training System, 3rd edition. Eklund, Bednarsh, and Haaland. Invision, Inc. 2008. Pages 3.6 – 3.7.
8) Google.com. Search for dental practice dress code. https://www.google.com/#q=dental+practice+dress+code Accessed on January 18, 2014.
9) US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. http://www.osha.gov/dcsp/osp/faq.html Accessed on January 18, 2014.